Motion for Leave to Withdraw and Motion to Extend Time to File Motion for New Trial — United States v. Baver (Dkt. 276, D. Utah)

Summary

A Motion for Leave to Withdraw and Motion to Extend Time to File Motion for New Trial in United States of America v. Allison Marie Baver, Case No. 2:21-cr-00520, in the U.S. District Court for the District of Utah, filed July 21, 2025. Defense counsel Alexander E. Ramos of Langford Ramos, PLLC and Nicolas C. Wilde move for leave to withdraw as counsel of record and ask that the assigned magistrate judge set a hearing. The motion states that the specific basis for withdrawal will be set out at a hearing in a non-public forum. It also asks the Court to extend the deadline for her motion for a new trial so that the withdrawal motion can be resolved first.

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Case 2:21-cr-00520-JNP           Document 276     Filed 07/21/25        PageID.4129    Page 1 of 2




 Michael Langford (9682)
 Alexander E. Ramos (15234)
 LANGFORD | RAMOS PLLC
 43 E. 400 S.
 Salt Lake City, UT 84111
 Telephone: (801) 998-2002
 Email: mjl@langfordramos.com
 Email: alex@langfordramos.com

 Nicolas C. Wilde (15768)
 Law Office of Nicolas C. Wilde LLC
 40 S. 600 E.
 Salt Lake City, Utah 84102
 T. 801-949-3088
 nick@ncwildelaw.com

 Attorneys for Defendant Allison Marie Baver


                         IN THE UNITED STATES DISTRICT COURT
                                   DISTRICT OF UTAH


  UNITED STATES OF AMERICA,                          Motion for Leave to Withdraw and Motion
                                                      to Extend Time to File Motion for New
       Plaintiff,                                                      Trial

  v.                                                 Case No. 2:21-cr-00520

  ALLISON MARIE BAVER                                District Judge Jill N. Parrish

       Defendant.                                    Magistrate Judge Cecilia Romero


          Undersigned counsel respectfully moves the Court for leave to withdraw as counsel of

 record for Allison Marie Baver Undersigned counsel request that the assigned Magistrate Judge

 set a hearing on this Motion.




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Case 2:21-cr-00520-JNP        Document 276        Filed 07/21/25     PageID.4130        Page 2 of 2




                                                  Motion

        Undersigned counsel respectfully move the Court for leave to withdraw as counsel of

 record for Allison Marie Baver. The specific basis for withdrawal will be outline in more detail

 at a hearing, in a non-public forum.

        Additionally, Ms. Baver moves the Court to extend the deadline for her Motion for a

 New Trial to allow enough time to resolve the Motion to Withdraw.




 RESPECTFULLY SUBMITTED this July 21, 2025.

                                                             Alexander E. Ramos
                                                             LANGFORD RAMOS, PLLC
                                                             /s/ Alexander E. Ramos




                                                             /s/ Nicolas C. Wilde
                                                             Nicolas C. Wilde
                                                             Law Office of Nicolas C. Wilde LLC

                                                             Attorneys for Defendant




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